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K., Estate of
(SSA Office of Hearings & App. Sept. 21, 1994). ; Clearinghouse Number: 50309
Description
Substantial Compliance with Regulations Entitles Claimant to Reimbursement for Skilled Nursing Facility Care
Abstract
The ALJ has held that, although claimant did not strictly comply
with Medicare regulations concerning the date of her admission to a
skilled nursing facility (SNF), her "substantial"
compliance with those regulations was sufficient to entitle her to
coverage. Under 42 C.F.R. § 409.30(b)(1), Medicare covers SNF
care only if the beneficiary enters the facility within 30 days of
discharge from the hospital. Claimant was initially discharged from
the hospital to her home. Within the 30-day period, she sought
admission to an SNF; however, for lack of certified beds, she was
not admitted until 32 days after her hospital discharge. The
intermediary denied payment on the grounds that the late admission
posed an absolute bar to Medicare eligibility. Reversing, the ALJ
held that it would be unjust to penalize claimant because of a
two-day delay that was out of her control. After review, the
Appeals Council found that the only exception to the 30-day
limitation, 42 C.F.R. 409.30(b)(2), allows a longer period if the
patient's condition makes it medically inappropriate to begin
an active course of treatment at an SNF and it is medically
predictable at the time of hospital discharge that the patient is
to require covered care within a predeterminable time period. The
Appeals Council remanded for a determination of whether claimant
met the exception. On remand, the ALJ held that, although claimant
did not meet the exception, she had substantially complied with the
30-day admission rule and therefore was entitled to coverage. The
ALJ found abusive and outrageous the benefit payment denial based
on the two-day delay in this case.
